IR 05000293/2019002
| ML19205A236 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 07/24/2019 |
| From: | Erin Carfang NRC/RGN-I/DRP/PB5 |
| To: | Brian Sullivan Entergy Nuclear Operations |
| Carfang E | |
| References | |
| IR 2019002 | |
| Download: ML19205A236 (16) | |
Text
uly 24, 2019
SUBJECT:
PILGRIM NUCLEAR POWER STATION - INTEGRATED INSPECTION REPORT 05000293/2019002 AND ASSESSMENT FOLLOW-UP LETTER
Dear Mr. Sullivan:
On June 10, 2019, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Pilgrim Nuclear Power Station (Pilgrim). On June 26, 2019, the NRC inspectors discussed the results of this inspection with you and other members of your staff. The results of this inspection are documented in the enclosed report.
The NRC inspectors did not identify any finding or violation of more than minor significance.
On June 10, 2019, Pilgrim certified the permanent removal of fuel from the reactor vessel (ADAMS Accession No. ML19161A033) and on June 11, 2019, the NRC notified Pilgrim that the Operating Reactor Assessment Program would cease, and that implementation of the Decommissioning Power Reactor Inspection Program would begin under the provisions in Inspection Manual Chapter 2561, Decommissioning Power Reactor Inspection Program (ADAMS Accession No. ML19162A033). The enclosed report will be the last Operating Reactor Assessment Program inspection report and this letter documents the final assessment results per the Operating Reactor Assessment Program for Pilgrim.
On June 26, 2019, the NRC completed its final quarterly performance assessment for Pilgrim in accordance with Inspection Manual Chapter 0305, Operating Reactor Assessment Program.
The NRC reviewed the most recent quarterly performance indicators and the inspection results and enforcement actions issued from January 1 through June 10, 2019. The assessment results in this letter supplement, but do not supersede, the annual assessment letter issued on March 4, 2019.
The NRC staff determined that overall, during this assessment period, Pilgrim operated in a manner that preserved public health and safety and met all cornerstone objectives.
Performance at Pilgrim during the most recent quarter remained within the Licensee Response Column, the highest performance category of the NRCs Reactor Oversight Process Action Matrix, because all inspection findings had very low safety significance (i.e., Green), and all performance indicators were within the expected range (i.e., Green). This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with 10 CFR 2.390, Public Inspections, Exemptions, Requests for Withholding.
Sincerely,
/RA/
Erin E. Carfang, Chief Reactor Projects Branch 5 Division of Reactor Projects Docket No. 05000293 License No. DPR-35
Enclosure:
As stated
Inspection Report
Docket Number: 05000293 License Number: DPR-35 Report Number: 05000293/2019002 Enterprise Identifier: I-2019-002-0040 Licensee: Entergy Nuclear Operations, Inc.
Facility: Pilgrim Nuclear Power Station Location: Plymouth, MA Inspection Dates: April 1, 2019 to June 10, 2019 Inspectors: E. Burket, Senior Reactor Inspector B. Pinson, Senior Resident Inspector K. Mangan, Senior Reactor Inspector O. Masnyk Bailey, Health Physicist J. Nicholson, Senior Health Physicist A. Patel, Senior Reactor Inspector S. Wilson, Health Physicist Approved By: Erin E. Carfang, Chief Reactor Projects Branch 5 Division of Reactor Projects Enclosure
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting a integrated inspection at Pilgrim Nuclear Power Station in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information.
List of Findings and Violations No findings or violations of more than minor significance were identified.
Additional Tracking Items Type Issue Number Title Report Status Section LER 05000293/2019-003-00 Condition Prohibited by 71153 Closed Technical Specifications Involving the Mechanical Vacuum Pump LER 05000293/2019-004-00 Manual Reactor Scram Due to 71153 Closed Degrading Condenser Vacuum
PLANT STATUS
The unit began the inspection period at rated thermal power. On April 8, 2019, operators reduced power to 42 percent to perform a mechanical backwash. On April 9, 2019, operations personnel returned the unit to rated thermal power. On May 17, 2019, operators manually scrammed the reactor due to degrading condenser vacuum following a trip of the 'B' seawater pump. On May 20, 2019, operators commenced a reactor startup and returned the unit to 50%
power on May 22, 2019. On May 31, 2019, operators shut down the unit in preparation for defueling.
INSPECTION SCOPES
Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors performed plant status activities described in IMC 2515, Appendix D, Plant Status, and conducted routine reviews using IP 71152, Problem Identification and Resolution. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.
REACTOR SAFETY
71111.01 - Adverse Weather Protection
Summer Readiness Sample (IP Section 03.01)
The inspectors evaluated summer readiness of offsite and alternate alternating current power systems the week of May 27, 2019.
71111.04 - Equipment Alignment
Partial Walkdown Sample (IP Section 03.01)
The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:
- (1) Residual heat removal following cross-tie system flushes on May 10, 2019
- (2) Spent fuel pool cooling system on May 16, 2019
- (3) Core spray system alignment following system flush on May 30, 2019
71111.05Q - Fire Protection
Quarterly Inspection (IP Section 03.01)
The inspectors evaluated fire protection program implementation in the following selected areas:
- (1) Emergency diesel generators (Zones 4.1, 4.2, 4.3, and 4.4) on April 9, 2019
- (2) 'A' switchgear and battery rooms (Zones 2.1 and 2.3) on April 11, 2019
- (3) Spent fuel pool cooling pumps and heat exchangers corridor (Zone 1.13) on April 18, 2019
- (4) Refuel floor (Zone 1.20) on May 28, 2019
71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance
Licensed Operator Performance in the Actual Plant/Main Control Room (IP Section 03.01)
The inspectors observed and evaluated activities associated with the following licensed operator performance in the control room:
Reactor startup following a manual scram initiated due to degraded condenser vacuum on May 20, 2019 Reactor shutdown for the defueling outage on June 1, 2019 Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)
The inspectors observed and evaluated licensed operator requalification training in the simulator on April 3, 2019.
71111.12 - Maintenance Effectiveness
Quality Control (IP Section 02.02)
The inspectors evaluated maintenance and quality control activities associated with performance activities of the O-ring lubricant used on 'A' emergency diesel generator air start solenoid valve on April 22, 2019.
Routine Maintenance Effectiveness Inspection (IP Section 02.01) (2 Samples)
The inspectors evaluated the effectiveness of routine maintenance activities associated with the following:
- (1) Spent fuel pool cooling and augmented spent fuel cooling systems during the week of May 13, 2019
- (2) Source range monitor maintenance effectiveness during the week of May 27, 2019
71111.13 - Maintenance Risk Assessments and Emergent Work Control
Risk Assessment and Management Sample (IP Section 03.01)
The inspectors evaluated the risk assessments for the following planned and emergent work activities:
- (1) Elevated risk with 'B' turbine building closed cooling water pump out-of-service on April 30, 2019
- (2) Verification of risk mitigating actions with K-110 instrument air compressor unavailable on May 2, 2019
- (3) Yellow shutdown risk with shutdown cooling in-service on May 19, 2019
- (4) Yellow risk due to high decay heat generation rate during the defueling outage (DFO22) on June 1, 2019
71111.15 - Operability Determinations and Functionality Assessments
Operability Determination or Functionality Assessment (IP Section 02.02)
The inspectors evaluated the following operability determinations and functionality assessments:
- (1) Operability of reactor protection system following failure of 'A' recirculation flow converter on April 5, 2019
- (2) Master feedwater level controller failure on April 11, 2019
- (3) 'A' residual heat removal pump operability following motor heater failure on April 30, 2019
- (4) 250 volt DC battery operability following discovery of elevated voltage readings on May 9, 2019
71111.17T - Evaluations of Changes, Tests, and Experiments Sample Selection (IP Section 02.01)
Between April 15-19, 2019, the inspectors reviewed the following evaluations, screenings, and/or applicability determinations to evaluate if Entergy's evaluations of changes, tests and experiments completed between March 2016 and March 2019 could be accomplished as outlined in 10 CFR 50.59 without prior NRC approval. In addition to the guidance in IP 71111.17T, the sample the inspectors selected were based on the guidance IMC 2515, Appendix G and were focused on those systems that may be in operation after the cessation of power operations.
- (1) SE3408, Use of 23kV Line #73 to provide power to the Shutdown Transformer when Line #108 is Out of Service
- (2) SE3411, Circuit Breaker A605 Fuse Wiring for Unit Aux Transformer Feeder Breaker
- (3) SE3412, Relocate Undervoltage Auxilliary Trip Relay for Breaker A501
- (4) SE3408, Procedure Changes to Respond to and Operate Core Spray/RHR Upon Loss of Keepfill System
- (5) SE3410, PNPS 4.3 Fuel Handling, UFSAR 14.5.5 Fuel Handling Accident"
- (6) EC 64142, Spent Fuel Pool Cleanup, Heavy Load Lifting of 8-120B Casks and Tri-Nuke Filters
- (7) EC 64762, Verify Acceptability to Operate Core Spray/RHR Upon Loss of Keepfill System
- (10) EC 68891, Flooding Mitigation Measures at the Turbine Building Trucklock Roll-Up Door
- (11) EC 69383, Remove Rubber Bumper on South Mechanical Stop for the Refuel Bridge Trolley
- (12) EC 70526, Temporary Modification to use Sand Bags at Door DR-311 while Modifying Flood Barrier
- (14) EC 74605, Generic Compensatory Measure for Degraded HELB/Tornado Door
- (15) EC 77811, Replace the Refuel Bridge Computer
71111.19 - Post-Maintenance Testing
Post Maintenance Test Sample (IP Section 03.01)
The inspectors evaluated the post maintenance tests for the following activities:
- (2) 'A' emergency diesel generator air start solenoid valve O-ring replacement (WO
===522753) on April 22, 2019
71111.20 - Refueling and Other Outage Activities
Refueling/Other Outage Sample (IP Section 03.01)
The inspectors evaluated the Pilgrim defueling outage (DFO22) activities from June 1-9, 2019. The inspectors verified the fuel was removed from the core on June 9, 2019.
71111.22 - Surveillance Testing
===The inspectors evaluated the following surveillance tests:
Surveillance Tests (other) (IP Section 03.01)===
- (1) 8.M.2-2.5.6, High pressure coolant injection condensate storage tank level functional test on April 11, 2019
- (2) 8.M.2-3.6.5, Attachment 4, 'B' recirculating flow converter calibration and functional test on April 12, 2019
- (3) 8.5.1.1, Section 8.2, 'B' core spray pump operability surveillance on April 17, 2019
71114.06 - Drill Evaluation
===Select Emergency Preparedness Drills and/or Training for Observation (IP Section 03.01) (1 Sample)
The inspectors evaluated the conduct of a routine Entergy decommissioning emergency plan drill on May 9,
RADIATION SAFETY
71124.04 - Occupational Dose Assessment
Internal Dosimetry (IP Section 02.03)===
The inspectors evaluated the following internal dosimetry program implementation:
Whole body counts There were no body counts performed during the inspection period. The whole body counter was out of service for approximately two years and no whole body counts were needed since returning the counter to operation. All individuals exiting the owner-controlled area were screened for radioactivity by GEM-5 personnel monitors (solid scintillation detectors).
In-vitro internal monitoring None were available during this inspection.
Dose assessments performed using air sampling and DAC-hr monitoring None were available during this inspection.
Special Dosimetric Situations (IP Section 02.04) ===
The inspectors evaluated the following special dosimetric situation:
Declared pregnant workers Two workers declared pregnancy during the inspection period. The individuals' declaration forms and exposure records were reviewed.
EDEX exposures None were available during this inspection. Station management has decided not to use EDEX at this time.
Shallow dose equivalent None were available during this inspection.
Neutron dose assessment Neutron dose tracking and personal dosimeter dose reports were reviewed.
71124.06 - Radioactive Gaseous and Liquid Effluent Treatment
===Calibration and Testing Program (Process & Effluent Monitors) (IP Section 02.02) (1 Sample)
The inspectors reviewed the following gaseous and liquid effluent monitor instrument calibrations and tests:
Liquid Radwaste Process Radiation Monitor RM-1705-30 calibration and functional checks completed in 2017 and 2018 Main Stack monitor calibration and functional checks for monitors RM-1705-18A and RM-1705-18B completed in 2017 and 2018 Radioactive Liquid Effluent Alternate Flow instrumentation LAHL-7124A, LAHL-7124B, LAHL-7124C calibration and functional checks completed in 2018 and 2019 NUMAC Process Radiation Monitor Calibration Instrumentation (RB Vent) RM-1705-32A calibration and functional checks completed in 2017 and 2018 Dose Calculations (IP Section 02.05)===
The inspectors reviewed the following to asses public dose:
No abnormal gaseous or liquid tank discharges were reported for the inspection period. The inspectors reviewed the following annual radiological effluent release reports:
2017 Annual Radioactive Effluent Release Report for January 1 through December 31, 2017 2018 Annual Radioactive Effluent Release Report for January 1 through December 31, 2018 2018 Annual Radiological Environmental Operating Report for January 1 through December 31, 2018
Instrumentation and Equipment (IP Section 02.04) (1 Sample)
The inspectors reviewed the following radioactive effluent discharge system surveillance test results:
Inspectors observed demonstration of electronic and radiation calibration of Area Radiation Monitor RIS-1815-2B located outside of the TIP room.
Air Cleaning System Surveillance Radioiodine Penetration and Efficiency Test Report for Standby Gas Treatment System (SBGT) 'B' dated March 30, 2018 HEPA Filter and Charcoal Cell Performance Tests per Procedure No. 7.1.30 for SBGT A and B dated March 20, 2018 Sampling of Charcoal Cells in SBGT and Control Room Environmental Filter Systems for Methyl Iodide Testing on SBGT A and B, dated March 20, 2018
Sampling and Analysis (IP Section 02.03) (1 Sample)
The inspectors reviewed the following radioactive effluent sampling and analysis activities:
Turbine Building Vent sample filter change and analysis on spectroscopy unit Effluent discharges Gaseous effluent discharges during the year 2018 as documented in the Annual Radioactive Effluent Release Report Main Stack Gaseous Effluent Particulates and Iodine results
Walk Downs and Observations (IP Section 02.01) (1 Sample)
The inspectors walked down the following gaseous and liquid radioactive effluent monitoring and filtered ventilation systems to assess the material condition and verify proper alignment according to plant design:
Liquid radwaste radiation monitoring system Reactor Building Vent effluent monitoring system Turbine Building Vent effluent monitoring system Main Stack monitoring system Control Room envelope ventilation system and filters Reactor Building ventilation system and filters
OTHER ACTIVITIES - BASELINE
===71151 - Performance Indicator Verification The inspectors verified licensee performance indicators submittals listed below:
IE01: Unplanned Scrams per 7000 Critical Hours Sample (IP Section 02.01) ===
For the period April 1, 2018 through March 31, 2019 IE03: Unplanned Power Changes per 7000 Critical Hours Sample (IP Section 02.02) (1 Sample)
For the period April 1, 2018 through March 31, 2019 IE04: Unplanned Scrams with Complications (USwC) Sample (IP Section 02.03) (1 Sample)
For the period April 1, 2018 through March 31, 2019
71152 - Problem Identification and Resolution
Annual Follow-up of Selected Issues (IP Section 02.03)
The inspectors reviewed the licensees implementation of its corrective action program related to the following issues:
Degraded trend on SF6 gas pressure for 345 kV offsite power line ring bus breaker, ACB-102 (CRs 2018-2542, 2018-9579, 2019-0414, and 2019-1906) on April 17, 2019.
Semiannual Trend Review (IP Section 02.02) (1 Sample)
The inspectors reviewed Entergys corrective action program for trends that might be indicative of a more significant safety issue.
71153 - Followup of Events and Notices of Enforcement Discretion Event Followup (IP Section 03.01)
Manual reactor scram following trip of 'B' seawater pump on May 17, 2019.
Event Report (IP Section 03.02) (2 Samples)
The inspectors evaluated the following licensee event reports (LERs) which can be accessed at https://lersearch.inl.gov/LERSearchCriteria.aspx:
- (1) LER 05000293/2019-003-00, Condition Prohibited by Technical Specifications Involving the Mechanical Vacuum Pump, (ADAMS Accession No.
ML19161A283). The circumstances surrounding this LER are documented in the Inspection Results section of this report.
- (2) LER 05000293/2019-004-00, Manual Scram Due to Degrading Condenser Vacuum (ADAMS Accession No. ML19162A032). The inspectors determined that it was not reasonable to foresee or correct the cause discussed in the LER, therefore, no performance deficiency was identified. The inspectors determined that there was no violation of NRC requirements.
INSPECTION RESULTS
Observation: Semi-Annual Trend Review 71152 The inspectors reviewed Entergys corrective action program for trends that might be indicative of more significant safety issues. The inspectors reviewed condition reports, maintenance backlogs, system health reports, and control room deficiencies. The inspectors evaluated both the number and the significance of condition reports generated during the first half of 2019 to identify any negative trends in problem identification and resolution. The inspectors determined that, generally, the condition report generation rate remained on par with previous years, and there was no indication of any significance misclassification. During the period of review, approximately 3300 condition reports were generated, 22 of them being classified as A or B significance, compared to approximately 4700 condition reports generated during the same period in 2018, where 50 were classified as A or B significance. The difference in total condition report generation and significance classifications were determined not to be significant when considering the number of maintenance activities and equipment challenges present in the first half of 2018 versus 2019.
Equipment reliability continued to challenge full power operations during the first half of 2019. Seasonally low tides, combined with degraded main condenser parameters and balance-of-plant equipment challenges contributed to a number of power reductions and extended operation at less-than-full power. Inspectors assessed and verified that actions taken in response to these challenges were appropriate for the significance of the issues. In particular, inspectors noted a bias towards conservative decision making when Entergy chose to operate at lower than rated thermal power levels for an extended period of time in order to reduce cycling of the plant. Additionally, inspectors noted that Entergy management continued to effectively track and implement corrective actions associated with safety and risk significant equipment throughout the period of review, including repairs of a feedwater regulating valve and a primary containment isolation valve in January 2019, and repair of a feedwater heating valve in March 2019.
Based on the overall results of the semiannual trend review, the inspectors determined that issues were appropriately evaluated by Entergy staff for potential trends and resolved within the scope of the corrective action program.
Minor Violation 71153 The failure to take actions associated with the mechanical vacuum pump isolation instrumentation as required by Technical Specification Action Statement 3.8.2.A.2.
As described in LER 05000293/2019-003-00, Entergy identified that on April 13, 2019, operators did not place the main steam process radiation monitor 1705-2D channel in the trip condition as required per technical specifications. Operators placed the channel in the inoperable condition, which does not enter a trip condition as required by Technical Specification 3.8.2.A.2. The main steam line process radiation monitor channels are designed to trip the mechanical vacuum pump and shut the associated isolation valves if main steam radiation levels exceed predetermined values. Placing the channel in trip when the channel is degraded ensures this design function is maintained.
Screening: The inspectors determined the performance deficiency was minor. When the process radiation monitor channel switch was in the incorrect position, main steam radiation conditions did not exist that required an isolation of the mechanical vacuum pump.
Therefore, there was no impact to the health and safety of the public.
Enforcement:
This failure to comply with Technical Specification 3.8.2.A.2 constitutes a minor violation that is not subject to enforcement action in accordance with the NRCs Enforcement Policy.
The disposition of this minor violation closes LER 05000293/2019-003-00.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
On June 26, 2019, the inspectors presented the integrated inspection results to Brian Sullivan and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection Type Designation Description or Title Revision or
Procedure Date
71111.04 Procedures 2.2.85 Fuel Pool Cooling and Filtering System 95
71111.12 Miscellaneous MRBD 19 10 CFR 50.65 Maintenance Rule Scoping Basis Document, 3
Fuel Pool Cooling System
71111.15 Corrective Action CR-PNP-2019-1935, CR-PNP-2019-2508
Documents
71111.17T Corrective Action CR-PNP-2019-2266, CR-PNP-2019-2281, CR-PNP-2017-
Documents 9900, CR-PNP-2017-9925, CR-PNP-2017-9967, CR-PNP-
2017-10877, CR-PNP-2017-10288, CR-PNP-2017-7320,
CR-PNP-2014-0861, CR-PNP-2013-1819, CR-PNP-2016-
7308, CR-PNP-2018-9794, CR-PNP-2011-4503, CR-PNP-
2016-8975
71111.17T Engineering EC 64142 Spent Fuel Pool Cleanup, Heavy Load Lifting of 8-120B 0
Changes Casks and Tri-Nuke Filters
71111.17T Engineering EC 64762 Verify Acceptability to Operate Core Spray/RHR Upon Loss 0
Changes of Keepfill System
71111.17T Engineering EC 67024 Evaluate RBCCW Pipe Wall External Corrosion 0
Changes
71111.17T Engineering EC 68229 Provide Tolerance Value for RHR Pump Motor Protective 0
Changes Relays
71111.17T Engineering EC 68891 Flooding Mitigation Measures at the Turbine Building 0
Changes Trucklock Roll-Up Door
71111.17T Engineering EC 69383 Remove Rubber Bumper on South Mechanical Stop for the 0
Changes Refuel Bridge Trolley
71111.17T Engineering EC 70526 Temporary Modification to use Sand Bags at Door DR-311 0
Changes while Modifying Flood Barrier
71111.17T Engineering EC 74553 Control Circuit Changes to MOV 1001-36A 0
Changes
71111.17T Engineering EC 74605 Generic Compensatory Measure for Degraded 0
Changes HELB/Tornado Door
71111.17T Engineering EC 77811 Replace the Refuel Bridge Computer 0
Changes
Inspection Type Designation Description or Title Revision or
Procedure Date
71111.17T Engineering EC 79602 Spent Fuel Pool Cooling Pump Alternate Power Supply 0
Changes RWCU Pump
71111.17T Engineering EC 80915 Temporary Leak Limiting Devise on SSW Spool JF29-9-1 0
Changes
71111.17T Engineering SE3408 Procedure Changes to Respond to and Operate Core 0
Changes Spray/RHR Upon Loss of Keepfill System
71111.17T Engineering SE3408 Use of 23kV Line #73 to provide power to the Shutdown 0
Changes Transformer when Line #108 is Out of Service,
71111.17T Engineering SE3410 PNPS 4.3 Fuel Handling, UFSAR 14.5.5 Fuel Handling 0
Changes Accident,
71111.17T Engineering SE3411 Circuit Breaker A605 Fuse Wiring for Unit Aux Transformer 0
Changes Feeder Breaker
71111.17T Engineering SE3412 Relocate Undervoltage Auxilliary Trip Relay for Breaker A501 0
Changes
71111.17T Miscellaneous 0000-0096-3671- Fuel Handling Accident in the Spent Fuel Pool Generic Dose Dated June
R0 Assessment 2009
71111.17T Miscellaneous BWROG-TP-10- Fuel Handling Accident in the Spent Fuel Pool Generic Dose 0
006 Assessment
71111.17T Miscellaneous M1416 Pipe Wall Thickness Requirements for Salt Service Water 0
Discharge Piping from SSW Pumps P208-A,B,C,E
71111.17T Procedures 2.2.19 Residual Heat Removal 115
71111.17T Procedures 2.4.A.23 Loss/Degradation of 23kV Line 28
71111.17T Procedures 4.3 Fuel Handling 134
71111.17T Work Orders WO 00456651
71153 Corrective Action CR-PNP-2019-2176, CR-PNP-2019-2431
Documents
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